As between each other, all mechanic's liens on a work of improvement relate back to the commencement of the work of improvement as a whole, regardless of when a particular lien
claimant began work or when a lien claim is recorded, and all recorded liens have the same priority.
While the super-priority status of a property tax lien may be relatively assured, and it is possible for a potential investor to make an informed judgment about the lien-to-value ratio of a particular lien
on a specific piece of property, a potential investor in a large volume of property tax liens faces two fundamental challenges which remain unresolved.
It is important for a lender to distinguish between the issue of whether a particular lien
is divested at a sheriff's sale, as opposed to whether a particular lien
is a superior lien for purposes of distribution of proceeds from the sale.